United States Courts of Appeals,
Eleventh Circuit 718 F.2d 1033
(11th Cir. 1983)
CJAD 405, Section A
June 08, 2011
Jimmy Maddox was convicted of rape in a Georgia state court and sentenced to life imprisonment. Having unsuccessfully pursued his direct appeal and the state post-conviction remedy, Maddox filed a federal habeas corpus petition alleging prosecutorial suppression of exculpatory evidence in violation of the doctrine of Brady v. Maryland. There are four types of situations in which the Brady doctrine applies; the prosecutor has not disclosed information despite a specific defense request, the prosecutor has not disclosed information despite a general defense request for all exculpatory information or without any defense request at all, the prosecutor knows or should know that the conviction is based on false evidence and or the prosecutor fails to disclose purely impeaching evidence not concerning a substantive issue, in the absence of a specific defense request. Issue:
Specifically, Maddox asserted that his right to due process was violated as outlined in violation of the doctrine of Brady v. Maryland by the state's failure to disclose a photograph taken by the police shortly after the alleged rape showing Elder's bed neatly made, the results of a police examination of the bedspread which revealed no blood, semen or other fluid, and lastly a written statement by another witness, Brenda Phelps, that Debbie Phillips had stated that she dropped her insurance with Maddox for financial reasons. Maddox appeals the denial of habeas relief. Decision of the Court:
The United States Court of appeals ruled that if the suppressed evidence is purely impeaching evidence and no defense request has been made, the suppressed evidence is material only if its introduction probably would have resulted in acquittal. Given the relatively minor role of Phillips' testimony and the limited...